How does the Intellectual Ventures I v. Capital One Bank case relate to mere instructions to apply an exception?
The Intellectual Ventures I v. Capital One Bank case provides an important example of how courts evaluate claims that may amount to mere instructions to apply an exception. According to MPEP 2106.05(f):
“In Intellectual Ventures I v. Capital One Bank, the claims recited a system for providing web pages tailored to an individual user, comprising an interactive interface having a display that depicts customized content based on (1) information known about the user and (2) navigation data. The court found that claiming the improved speed or efficiency inherent with applying the abstract idea on a computer was insufficient to render the claims patent eligible as an improvement to computer functionality.”
This case demonstrates that merely implementing an abstract idea on a computer, or using a computer as a tool to perform an abstract idea, is not enough to make the claim patent-eligible. Even if the computer implementation results in improved speed or efficiency, this alone is not sufficient to transform the abstract idea into a patent-eligible invention. The claims must provide something more than just applying the abstract idea using generic computer components.
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